NGO Responds to Game Rearing Code
15 January 2010
The National Gamekeepers' Organisation has formally responded to a Defra consultation on a Game Rearing Code for England, which closes on Monday. The NGO wrote:
General Comments
As one of the bodies represented on the Defra Gamebird Working Group, which helped to write the code for gamebird rearing in England, the National Gamekeepers' Organisation (NGO) has given the draft sent out for public consultation last November a warm welcome. When the draft was published, we issued the following press release expressing our support:
http://www.nationalgamekeepers.org.uk/news/45/
The NGO represents gamekeepers in England and Wales and has 14,500 keeper and supporter members. Many of the estates and shoots buying gamebirds from UK and overseas game farms have NGO members as their gamekeepers and several thousand of our members are also involved in game rearing programmes of their own.
We want to see high standards throughout shooting and gamekeeping. Bird welfare during the rearing process is particularly important. The NGO has long supported the Game Farmers Association's voluntary Code of Practice as a good standard for all who rear gamebirds and, though our support of the wider Code of Good Shooting Practice, we expect our members to be guided by it.
The proposed Defra code is closely modelled on the pre-existing GFA Code and, having been part of the Working Group which examined and amended that text, the NGO is content with the code in the form it has been sent out for consultation. To us it combines the essential characteristics of simplicity and practicality with a good base standard of animal welfare.
On the unresolved issue of raised laying units/cages, our settled policy is on our website at:
http://www.nationalgamekeepers.org.uk/library/resource/39/
In essence, we think that good management within any system is more important than the type of system itself and we believe that individual shoots and gamekeepers should be left to decide for themselves which laying/rearing systems to use or to buy from. As long as legislation requires a satisfactory overall welfare outcome - which the 2006 Act and the proposed code will do - the choice of system should be a matter for individuals and not for Government.
Answers to Defra's Specific Questions
Within Defra's consultation document there are 17 questions for stakeholders to answer. Our response to these follows and if we can help amplify them in any way we will be pleased to do so.
Q1. Do you agree that a code of practice is the most appropriate option or do you consider that game farms should be regulated?; if so, who should regulate them?
We agree that a code of practice is the right approach. Regulation would be going too far. Apart from large game farms, there are many individuals who rear modest numbers of gamebirds, including many of our members. It would be hard to regulate for these very differing scales and systems of rearing. A code that sets out the basic welfare principles is clearly the right approach.
Q2. Do you think that a code reflecting the gamebird rearing season is the most sensible approach?
Yes. It will be easier to understand and follow if set out that way.
Q3. Is it clear and easily understandable?
Yes. Defra just needs to make sure that in any accompanying publicity it is made clear that the code applies to all who rear, and not just to game farmers. The consultation document is unclear on this point although the text of the draft code itself is fine.
Q4. Or do you think it should be set out in the alternative format with sections relating to each of the animal's five needs?
No.
Q5. Is it useful to have an Annex containing information on other legislation affecting gamebirds?
Yes, very. Knowing which of the many laws applies is far from easy.
Q6. Are there any additional recommendations that should be in the code?
No. The Defra Working Group spent many months considering all aspects of rearing and everything that needs to be covered in the code is already in there. Things which are not included were left out for the very good reason that rearing systems are highly varied. Getting too specific in the text of the code would therefore be problematic. The code as drafted combines a good standard of welfare with the flexibility to rear birds in different ways. This is important.
Q7. Do you consider that cages can provide adequately for the welfare needs of breeding pheasants? Or do you consider that barren cages should not be used for the housing of breeding pheasants? Or do you consider that all cages for breeding pheasants should not be used?
Barren cages should not be used for pheasants because by definition they cannot provide for the birds needs in accordance with the Animal Welfare Act. We can see no justification, however, for banning cages that do provide for the birds welfare needs and we therefore support Option 2 under paragraph 6.11. It would be good to have more research on which to base the design, enrichment and management of cages so as to ensure that they provide for the birds' needs and we regret that Defra has had to cancel the research programme on which it was about to embark. In the meantime, the advice of the Farm Animal Welfare Council and the Defra Gamebird Working Group should be followed, which was that barren systems should not be used.
Q8. Do you consider that cages can provide adequately for the welfare needs of breeding partridges? Or do you consider that barren cages should not be used for the housing of breeding partridges? Or do you consider that all cages for breeding partridges should not be used?
Barren cages should not be used for partridges but properly enriched and well-managed raised pair units which provide for all the birds needs should be allowed. This middle way (Option 2) was what FAWC recommended and we see no justification to go further. A total ban on all cages would affect lots of our members, who either used raised partridge systems or who buy eggs, chicks or poults from them. It would just have the effect of exporting partridge egg production overseas, where the French in particular are just waiting to snap up more business from the UK.
Q9. Do you consider that having a standard definition for a cage is necessary for a clear understanding by keepers if cages are to be restricted or banned? If so would the EFSA definition be a suitable approach?
No. A definition of a cage would be problematic and arbitrary. The key thing is that any system should provide for the needs of the birds - which is what the Act and the code require. Anything that does not provide for those needs should not be allowed and would not be allowed under the code and Option 2. It is the result in terms of bird welfare that matters, not the name or definition given to any particular system.
Q10. Do you consider that setting space allowance for breeding pheasants and partridges would address the concern?
No. See above. Setting arbitrary space allowances would not guarantee good welfare and there is insufficient evidence available to do so. The issue of whether or not there is sufficient space is best judged by the condition of the birds. In any case, poorly treated birds do not perform well so it is in the producer's interests to make sure his system is well-designed and managed.
Q 11. What would be the space allowance for an adult pheasant and what is the evidence that this is appropriate?
We oppose the setting of arbitrary space requirements. The issue should be judged by outcomes. ‘Enough to ensure good bird welfare and the birds needs' is the answer and that will vary depending on the system. Things like enrichment and, in particular, the standard of management will make a big difference. Isolating space as an issue is illogical and misleading. Any laying system has to be looked at in the round.
Q12. What would be the space allowance for an adult partridge and what is the evidence that this is appropriate?
See Q11.
Q13. Do you agree that spectacles should not be used? Or do you consider that spectacles have welfare benefits provided they are used appropriately?
We support the wording used in the draft code that ‘spectacles should not generally be used.' This wording makes it quite clear that the expectation is that specs will not be used, but it also provides that in really exceptional circumstances someone may be able to justify their use within the code.
Q14. Do you agree that the use of bits for younger pheasants should continue when justified, monitored and fitted on an enterprise-by-enterprise basis as described above?
The correct use of bits is absolutely fundamental to the continuance of game rearing and shooting in this country and they should always be monitored and justifiable on a case-by-case basis. The recent studies by the GWCT showed that without bits, welfare would be worse.
Q15. Do you agree that bumpa bits should only be used in exceptional circumstances?
Yes.
Q16 Is this a fair assumption?
So far as we are aware, your assumptions on the numbers of cage users etc in the UK are reasonable.
Q17. Are these estimates reasonable?
We find the figures in the draft impact assessment rather hard to follow but as far as we can see the assumptions behind them appear to be about right.